In the case of State of Oklahoma v. State of Texas, 1924, the U.S Supreme Court was tasked with resolving a boundary dispute between Oklahoma and Texas over the Red River. The controversy arose due to changes in the river's course which led to uncertainty about state boundaries. The United States intervened as it held title to certain lands along this disputed area under public domain laws. After considering historical treaties, maps and other evidence, the court ruled that when rivers serving as boundaries change gradually through erosion or accretion (natural processes), state lines move accordingly; however if they shift suddenly due to avulsion (a rapid change such as flooding), borders remain fixed at their pre-change location. As per these principles, most of disputed land fell within Texan jurisdiction but some parts were deemed part of Oklahoma territory where avulsive shifts had occurred earlier.

In the dissenting opinion for the case of State of Oklahoma v. State of Texas, Justice Oliver Wendell Holmes Jr. disagreed with the majority's decision to grant ownership rights over a disputed portion of land along the Red River boundary to Texas. He argued that historical evidence and previous agreements between states should be considered in determining jurisdictional boundaries rather than relying solely on physical geography or natural landmarks which can change over time due to environmental factors such as erosion or flooding. Furthermore, he contended that granting ownership based on current geographical features could potentially lead to future disputes if these features were altered naturally in years ahead. Therefore, he believed it was more prudent and fairer for all parties involved if past treaties and agreements were taken into account when deciding state boundaries.